RP Golf v. Commissioner, No. 16-3277 (8th Cir. 2017)
Annotate this CasePetitioner claimed a charitable deduction of $16.4 million for donating an easement, but the Commissioner disallowed the deduction. The Eighth Circuit affirmed the tax court's ruling in favor of the Commissioner because petitioner did not make a qualified contribution easement pursuant to 26 U.S.C. 170(b)(1)(E). In this case, because the banks' mortgages were not subordinated before the charitable conveyance occurred in December 2003, petitioner was not entitled to a deduction on its 2003 tax return for a qualified conservation contribution.
Court Description: Benton, Author, with Smith and Shepherd, Circuit Judges] Petition for Review - Commissioner of Internal Revenue. Tax Court determination that taxpayer did not make a "qualified contribution easement" under 28 U.S.C. Sec. 170(b)(1)(E) is affirmed.
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